The proposed regulations do not reflect our current understanding of best practices for high abilty and high potential learners.  They do not recognize the complex needs of academically diverse schools and classrooms--or of the students who constitute those schools and classrooms. They were developed without input from critical stakeholders and experts on gifted education in the state of Virginia.  In many respects, they are more representative of thinking in 1970 or 1980 than 2008.